Internal Revenue Bulletin: 2007-30
July 23, 2007
Table of Contents
Low-income housing credit; satisfactory bond; “bond factor” amounts for the period January through September 2007. This ruling provides the monthly bond factor amounts to be used by taxpayers who dispose of qualified low-income buildings or interests therein during the period January through September 2007.
Insurance premium. This ruling holds that an arrangement that provides for the reimbursement of inevitable future costs does not involve the requisite insurance risk for purposes of determining (i) whether the amount paid for the arrangement is deductible as an insurance premium and (ii) whether the assuming entity may account for the arrangement as an ‘insurance contract’ for purposes of subchapter L of the Code. Stakeholders are asked to comment on the application of the rationale of the revenue ruling outside of its facts. Rev. Rul. 89-96 amplified.
Nonexempt employees’ trusts. This ruling considers the federal tax consequences to the employees, the employer, and the trust when an employer contributes to a nonexempt employees’ trust on behalf of highly compensated employees. It also explains the effects of vesting of an employee’s interest in the trust and distributions from the trust. Rev. Rul. 74-299 amplified.
This notice provides a proposed revenue procedure that establishes a procedure for a payment card organization to request a determination that it is a Qualified Payment Card Agent (QPCA).
Accounting for advance trade discounts. This procedure provides that the Service will follow Westpac Pacific Food v. Commissioner, 451 F.3d 970 (9th Cir. 2006) with respect to taxpayers that adopt the Advance Trade Discount Method of accounting as provided in this procedure. The document also provides procedures for obtaining automatic consent to change to this method of accounting. Rev. Proc. 2002-9 modified and amplified.
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